Spouses Carmelito v. The Court of Appeals

Summary

This case involves a complex property dispute over a 4,044-square meter lot in Pasig City. The registered owners (Reyeses) mortgaged the property to petitioner Aldover, who foreclosed when they defaulted. However, 315 respondents claimed ownership/possession of portions of the lot through prior sales and lease agreements with the Reyeses, some predating the mortgage. When Aldover sought demolition after obtaining a writ of possession, respondents filed for injunctive relief. The Supreme Court affirmed the Court of Appeals' grant of preliminary injunction, holding that respondents' actual possession created a disputable presumption of ownership under Article 433 of the Civil Code. The Court emphasized that third parties holding property adversely to judgment debtors cannot be dispossessed through ministerial writs but require proper judicial proceedings. The decision protects due process rights and recognizes that prior unrecorded sales may prevail over subsequent recorded mortgages, highlighting the complexity of property rights when multiple parties have competing claims.